Mayo Foundation for Medical Education and Research, et al., Petitioners v. United States (562 U.S. 44)
U.S. Supreme Court · decided January 11, 2011 · Supreme Court Database (Spaeth)
- Citation
- 562 U.S. 44 · 131 S. Ct. 704
- Decided
- January 11, 2011
- Term
- October Term 2010
- Vote
- 8–0
- Majority author
- Justice Roberts
- Issue area
- Federal Taxation
- Disposition
- Affirmed
- Outcome
- Petitioning party lost
- Ideological direction
- Liberal
Opinion excerpt
Chief Justice Roberts delivered the opinion of the Court. Nearly all Americans who work for wages pay taxes on those wages under the Federal Insurance Contributions Act (FICA), which Congress enacted to collect funds for Social Security. The question presented in this case is whether doctors who serve as medical residents are properly viewed as “student[s]” whose service Congress has exempted from FICA taxes under 26 U. S. C. § 3121(b)(10). I A Most doctors who graduate from medical school in the United States pursue additional education in a specialty to become board certified to practice in that field. Petitioners Mayo Foundation for Medical Education and Research, Mayo Clinic, and the Regents of the University of Minnesota (collectively Mayo) offer medical residency programs that provide such instruction. Mayo’s residency programs, which usually last three to five years, train doctors primarily through hands-on experience. Residents often spend between 50 and 80 hours a week caring for patients, typically examining and diagnosing them, prescribing medication, recommending plans of care, and performing certain procedures. Residents are generally supervised in this work by more senior residents and by faculty members known as attending physicians. In 2005, Mayo paid its residents annual “stipends” ranging between $41,000 and $56,000 and provided them with health insurance,…
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